Introduction

In a fluid global economic landscape, operational demands may take precedence in a business, but appropriate operational structuring supported by robust transfer pricing policies is of paramount importance to any cross-border business.

Assessing a global group’s activities and applying an appropriate remuneration model to meet operational and regulatory needs is often a moving target. Employees move, sales patterns and processes change, or new tariffs are introduced causing fundamental changes to operating models. Furthermore, the Organisation for Economic Corporation and Development (OECD) or different jurisdictions may change their approach to transfer pricing compliance causing headaches for businesses.

Our dedicated transfer pricing team help our clients navigate the transfer pricing landscape using their decades of experience.

Modelling

Most businesses aspire to operate globally and where there are cross-border transactions involving related parties, the operational model and transfer pricing policies will need to be considered.

We will work with our clients to advise on the appropriate remuneration models based on the functional and economic analyses.

Reporting

Different jurisdictions have different reporting requirements but ultimately, the OECD guidelines set out the overarching principles for transfer pricing reporting. This may include the preparation of transfer pricing master files (parent / group level) and local files (subsidiary level) in line with the OECD guidelines. The preparation of robust functional and economic analyses supported by benchmarking is an essential part of the annual reporting cycle.

Support

Our team has experience in dealing with queries from stakeholders including tax authorities, due diligence teams and auditors. We provide assistance to clients dealing with these queries and help businesses to provide the right information and evidence to support positions.

We also offer a risk review service to evaluate transfer pricing processes to help clients identify risks and offer solutions to mitigate these risks.

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